RJ 330: disclosing transactions with related parties
Does the BV rent a building from the director, lend money to the shareholder or buy from a sister company? Then a reader wants to know whether that happens on arm's length terms. RJ 330 and the law determine when you must say so.
The short answer
A large entity discloses important transactions with related parties that were not entered into on normal market terms: size, nature of the relationship and whatever else is needed for the insight (art. 2:381(3) DCC; RJ 330). A medium-sized NV does so in a limited way; other medium-sized entities, such as the BV, and small entities need not. Loans to directors are also disclosed by small.
Updated 30 October 2026
Key facts
| Guideline | RJ 330 Related parties (unchanged since the 2020 version, in force from financial year 2019); in the RJk A5 has lapsed and the disclosure for small is optional (RJk B18.102) |
| Legal basis | art. 2:381(3) DCC, with the definition of IAS 24; loans to directors and supervisory directors in art. 2:383(2) DCC |
| Mandatory for | Large in full; medium-sized NV limited (art. 2:397(6) DCC); not for other medium-sized entities, such as the BV, and not for small and micro |
| Group exemption | Transactions with subsidiaries wholly owned by the group need not be disclosed |
Who is a related party?
It is disclosed which transactions of significance were not entered into by the entity on normal market terms with related parties as referred to in the standards adopted by the International Accounting Standards Board and approved by the European Commission, the size of those transactions, the nature of the relationship with the related party, as well as other information on those transactions that is necessary to give insight into the financial position of the entity.
For the definition the law refers to IAS 24. Related, in essence, are: whoever has control, joint control or significant influence over the entity; the directors and other key management personnel of the entity and of its parent; the close family of all those persons; and the companies they control. Also the parent, subsidiaries and fellow subsidiaries in the group, participations, joint ventures and pension funds for the staff. For the average DGA structure that means: the holding, the DGA, his partner and children, the operating companies and every other BV of the DGA.
What you disclose
The statutory duty concerns only transactions that are of significance and were not concluded on normal market terms. You disclose the size, the nature of the relationship and whatever else is needed to understand the consequences for the financial position. You may combine similar transactions. What happens within the group with wholly owned subsidiaries you may omit (art. 2:381(3), second and third sentence).
RJ 330 supplements that. Whether a transaction is of significance, you assess with the ordinary materiality rules (RJ 330.202). Useful are the size as an amount or percentage, the outstanding balance and the pricing policy (RJ 330.204). You group by kind of relationship: parent, parties with joint control or influence, group companies, participations, joint ventures, key management personnel and others (RJ 330.206). Transactions on market terms you need not disclose, but the Council (Raad voor de Jaarverslaggeving) recommends it (RJ 330.201). RJ 330 concerns only the notes; the accounting for profit on transactions within the group is in RJ 260.
Loans to directors: also for the small BV
Besides the disclosure on related parties, art. 2:383(2) DCC asks for disclosure of loans, advances and guarantees to directors and supervisory directors: the outstanding amount, what has been written off or forgiven, the interest, the main terms and the repayments in the year. That provision also applies to a small entity; only the micro entity is exempt (RJk B5.106; art. 2:395a(6) DCC). A debit balance in a current account with the DGA is such a loan if the DGA is a director.
Case: rent, current account and purchases from a sister company
Bouwbedrijf Van Leeuwen is owned by Van Leeuwen Holding BV, which is wholly owned by the DGA. The DGA is also a director of the construction company. In 2025 the following happens:
- The construction company rents a warehouse from the DGA privately for € 96.000 per year. A valuer estimates the market rent at € 60.000.
- The DGA has a debit balance in current account of € 80.000, interest-free, with no repayment schedule.
- The construction company buys € 1,2 mln of materials from a sister company under the holding, at the same prices as for third parties.
| Disclosure | As a large BV | As a medium-sized NV | As a medium-sized or small BV |
|---|---|---|---|
| Rent from the DGA above market rent | Yes: € 96.000 per year, relationship director and indirect shareholder, difference from the market | Yes: transaction with a director and the major shareholder | Not mandatory; small may do so voluntarily |
| DGA current account € 80.000 | Yes, as a loan to a director (amount, 0% interest, no repayment schedule) and as a non-arm's-length transaction with a related party | Same: loan to a director and transaction with the major shareholder | Only as a loan to a director; small also discloses this |
| Purchases from the sister company € 1,2 mln | Not mandatory (at market terms); recommended | Not mandatory | Not mandatory |
For tax purposes, rent above the market and an interest-free loan also raise the question of non-business conduct (onzakelijkheid); that is a different test from the disclosure in the annual accounts.
Per size class
| Class | Related parties (art. 2:381(3) DCC) | Loans to directors (art. 2:383(2) DCC) |
|---|---|---|
| Micro (assets ≤ € 450.000, net turnover ≤ € 900.000, < 10 employees) | No | No |
| Small (assets ≤ € 7,5 mln, net turnover ≤ € 15 mln, < 50 employees) | No (art. 2:396(5) DCC); voluntary is possible (RJk B18.102) | Yes |
| Medium-sized (assets ≤ € 25 mln, net turnover ≤ € 50 mln, < 250 employees) | NV: only transactions with major shareholders and with directors and supervisory directors (RJ 330.203); other medium-sized entities, such as the BV: no | Yes |
| Large | Yes, per category (RJ 330.206) | Yes; the public NV per person (art. 2:383e DCC) |
The exemption for medium-sized does not apply to a listed company (RJ 330.203). Other chapters too ask for information on related parties, such as pension funds in RJ 271 and share-based arrangements that a shareholder settles in RJ 275 (RJ 330.207).
What differs per financial year
For financial years 2025, 2026 and 2027, RJ 330 is the same. One change around it: from 2026 a share-based arrangement that a shareholder outside the consolidation group settles need not be accounted for under RJ 275, but the disclosure as a related party transaction remains (RJ 275.103a and 275.511). Separately, since 2019 listed companies have a reporting duty for material transactions with related parties outside the normal course of business or market terms, at the time they are entered into (art. 2:167 to 2:170 DCC; RJ 330.101).
Common mistakes
- Seeing only the holding as a related party and forgetting the DGA, his family and his other BVs.
- Explaining related parties at length at a medium-sized BV, while a loan to the director is missing.
- Disclosing an interest-free current account without interest or repayment arrangements.
- Presenting arm's-length intercompany purchases as a non-arm's-length transaction.
How it works in Jaarrekening.io
Jaarrekening.io asks a large entity about non-arm's-length transactions with related parties per category, a medium-sized NV for the limited disclosure, and a small entity only whether it wants to disclose something voluntarily; a medium-sized BV gets the questions only if it switches that section on itself. The question on loans to directors and supervisory directors is mandatory for small, medium-sized and large and a free choice for micro.
Sources
- Art. 2:381 DCC: commitments and related parties (wetten.overheid.nl)
- Art. 2:383 DCC: remuneration and loans of directors and supervisory directors
- Art. 2:397 DCC: medium-sized entities, paragraph 6
- Dutch Accounting Standards Board (Raad voor de Jaarverslaggeving): the Guidelines and the compilations (rjnet.nl)
Frequently asked questions
Must a small BV disclose transactions with related parties?
No. Art. 2:381(3) DCC does not apply to small entities (art. 2:396(5) DCC); the RJk leaves it to the entity (RJk B18.102). A loan or advance to a director, such as a debit balance in the DGA's current account, a small BV does disclose, with interest, terms and repayments (art. 2:383(2) DCC).
Must I also disclose transactions on market terms?
The law asks only for transactions of significance that were not entered into on normal market terms. RJ 330.201 recommends also disclosing important transactions on market terms. That is a recommendation, not a duty.
Who are the related parties of a BV with a holding and a DGA?
In any case the holding, the DGA and his close family, the other companies that the DGA or the holding controls, and the directors and supervisory directors. For the definition the law refers to IAS 24.
Does the exemption for medium-sized also apply to an NV?
Partly. A medium-sized NV discloses transactions entered into directly or indirectly with its main shareholders and with its directors and supervisory directors (art. 2:397(6) DCC). A medium-sized BV is fully exempt, and a listed company cannot use the exemption.
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